1. This policy of http://www.expertoption.com
and its affiliates (hereinafter referred to as the “Company”)
to prohibit and actively pursue the prevention of money laundering
and any activity that facilitates money laundering or the funding
of terrorist or criminal activities. Company requires its officers,
employees and affiliates to adhere to these standards
in preventing the use of Company’s Services for money laundering
purposes.

2. For the purposes of this policy, money laundering is generally
defined as engaging in acts designed to conceal
or disguise the true origins of criminally derived proceeds
so that the unlawful proceeds appear to have been derived from
legitimate origins or constitute legitimate assets.

3. Generally, money laundering occurs in three stages. Cash first enters
the financial system at the “placement” stage, where the cash generated
from criminal activities is converted into monetary instruments, such
as money orders or traveler’s checks, or deposited into
accounts at financial institutions. At the “layering” stage, the
funds are transferred or moved into other accounts or other
financial institutions to further separate the money from its criminal
origin. At the “integration” stage, the funds are reintroduced into the
economy and used to purchase legitimate assets or to fund other
criminal activities or legitimate businesses. Terrorist financing may not
involve the proceeds of criminal conduct, but rather an attempt
to conceal the origin or intended use of the funds, which will
later be used for criminal purposes.

4. Each employee of Company, whose duties are associated with the
provision of products and services of Company and who directly
or indirectly deals with Client of Company, is expected
to know the requirements of the applicable laws and regulations
which affect Client’s job responsibilities, and it shall be the
affirmative duty of such employee to carry out these
responsibilities at all times in a manner that complies with
the requirements of the relevant laws and regulations.

5. To ensure that this general policy is carried out, management
of Company has established and maintains an ongoing program for the
purpose of assuring compliance with the relevant laws and regulations and
the prevention of money laundering. This program seeks to coordinate
the specific regulatory requirements throughout the group within
a consolidated framework in order to effectively manage the
group’s risk of exposure to money laundering and terrorist financing
across all business units, functions, and legal entities.

6. Each of the Company’s affiliates is required to comply with
AML and KYC policies.

7. All identification documentation and services records shall be kept
for the minimum period of time required by local law.

8. All new employees shall receive anti-money laundering training as part
of the mandatory new-hire training program. All applicable employees are
also required to complete AML and KYC training annually. Participation
in additional targeted training programs is required for all
employees with day to day AML and KYC responsibilities.

9. Сlient is obliged:

9.1. to respect any requirements of law, including international,
directed on fight against illegal trade, financial frauds, washing and
legalization of the money received in the illegal way;

9.2. to exclude direct or indirect complicity of illegal
financial activities and to any other illegal Operations with use
of the Site.

10. Client guarantees a legal origin, legal ownership and availability
at Client of the actual right to use of the money
transferred by Client to Client’s Account.

11. The Company reserves the right to conduct “Know your customer” (KYC)
and/or “Anti-money laundering/Counter-terrorist Financing” (AML/CTF) checks
and procedures on Clients in accordance with applicable laws and regulations
in Republic of Vanuatu to prevent money laundering and/or terrorism financing
and any transaction or activity that facilitates money laundering and/or
terrorism financing.

The Company may, at its sole discretion, request identity verification from
the Client to comply with applicable AML/CTF laws and regulations and to
protect the Company from potential association or involvement with money
laundering or other criminal activities.

The Client undertakes to provide all documents and/or information requested by
the Company in respect of conducting KYC or AML/CTF checks/procedures. In the
event that the Client fails or refuses to provide the specific and necessary
documents and/or information requested by the Company in due time, the Company
reserves the right to postpone processing Client’s requests for deposit, trade
execution and/ or withdrawal and to stop providing services to that Client
without any obligation from the Company to indemnify the Client until the
Client’s KYC documents are received, reviewed and verified.

12. In case of suspicious or fraudulent cash replenishments, including use of
the stolen credit cards and/or any other activities of fraudulent nature
(including any returns or cancellations of payments), Company reserves the
right to stop provision of Services and to block Client’s Account, and also to
cancel results of any Operations performed by Client and to investigate
Operations of doubtful nature owing to what to suspend such Operations before
clarification of the nature of emergence of money and the end of
investigation.

13. During the investigation Company reserves the right to request from Client
of the copy of the identity certificate (passport) and bank cards used for
account replenishment, the payment, and also other documents confirming legal
possession and a legal origin of money.

14. Client is forbidden to receive and use Services and/or the software for
any illegal or fraudulent action, or for any illegal or fraudulent Operations
(including money laundering) according to the legislation of the country of
jurisdiction of Client or Company.

15. Refusal of Company of carrying out suspicious Operations isn’t the basis
for any Company’s civil responsibility before Client or other third parties
for non-execution of any liabilities in relation to Client.